Provost's Long View: A rolling TEF, a periodic
REF, farewell HEFCE and a proposed new 'Office for Students' - the government's
green paper on higher education

19 November 2015

For the second time in a year, I will start my column by
expressing the collective sorrow of UCL for the recent horrific attacks in
Paris and the tragic loss of life.

As I heard one TV commentator say, if the
Charlie Hebdo episode was about attacking French values and freedom of speech, this
weekend saw a direct attack on France and its citizens.

As I write, it is emerging that five British citizens also
lost their lives. Our thoughts and condolences go to the families of all the
victims and to the people of Paris and France at this tragic time. Flags at UCL
will be flown at half mast this week as a mark of respect for all those that
lost their lives. We are a university with staff and students from all around
the world and I recognise that terrorism has impacted on many communities globally
- I want also to extend my thoughts on behalf of UCL to everyone affected by
such violence in recent times.

Moving from something so serious and tragic to an analysis
of the key features of the government's green paper on higher education is not
an easy transition, but it is really important that our views are expressed, because
this document signals a very important series of changes to the funding and
regulation of higher education that have the potential to impact significantly
on UCL and our future.

What does the
consultation draft cover?

In this column, it isn't going to be possible to cover all
the detail, but you can view
the full green paper, which contains a short executive summary of the
proposed changes on pages 10-17. I will comment on a few key issues that strike
me as important aspects for discussion.

The first point to note is that it is a 'green paper', and it
is therefore open to consultation. In fact, the document poses some 28 questions
throughout its 105 pages of text, with a submission date for responses of 15
January 2016. UCL will contribute to the Russell Group's response to the green
paper and we will also send in an institutional response that will shortly be
drafted and that will be signed off through our senior management team (SMT). The
NUS will work with students' unions, including UCLU, to formulate a response to
the green paper on behalf of the student body.

As well as these specific questions, it also seems to me important
to consider what should or might also have been asked. This
is a document that largely focuses on conventional home/EU undergraduate
education for 18-23 year olds. It pays relatively little attention to part-time
or postgraduate students, which seems like a lost opportunity. The big positive
of the document is the focus on putting students at the centre of higher education.
While that is a laudable aim, it is debatable whether the proposals are capable
of achieving it in their current form.

Teaching 'regarded
as a poor cousin to academic research'

A central theme of the green paper is that teaching is not
valued as highly as research in our universities, and that something must be
done (by government) to correct that. I quote a few lines from the green paper to
give you the flavour, firstly from the Minister for Science and Universities,
Jo Johnson:

"For too long, teaching has been regarded as a poor cousin
to academic research. The new Teaching Excellence Framework, which we promised
in our manifesto, will hard-wire incentives for excellent teaching and give
students much more information both about the type of teaching they can expect
and their likely career paths after graduation."

And then further into the detail of the document:

"There is evidence to suggest that 'strong orientations
towards research often reveal a weak emphasis on teaching, and vice versa'. At
its most extreme, because some universities see their reputation, their
standing in prestigious international league tables and their marginal funding
as being principally determined by scholarly output, this can result in
teaching becoming something of a poor cousin to research in parts of our
system."

As a central tenet of the green paper, I would suggest that
this assertion is fundamentally flawed and I feel duty-bound to defend the
track record of student education by our nation's research-intensive
universities, and particularly UCL.

We are not driven by national or global league table
positions, nor solely by the reputation of our research. We are driven by
academic excellence and by applying that excellence to have an impact on the
society in which we live, both national and global. Such impact is driven forward
as much by our world-class graduates as it is by our research and innovation.
We have always seen this set of issues in the round.

UCL's approach to
education not reflected in the green paper

In the same vein, the green paper pays scant attention to how
world-class research directly relates to international excellence in education.
UCL's strategic emphasis on a research-based pedagogy for our student education
seeks to enable our students to become critical and independent thinkers,
creative problem-solvers, team players and great communicators. The benefits of
this type of approach appear, at best, to be misunderstood in this green paper.

I am confident that our students leave UCL well equipped with
the skills and experience that they need to adapt to the varied careers that they
will pursue over their lifetimes .
They may not always be fully prepared to step into specific individual careers
at their point of departure from UCL, as the green paper seems to request, but
they are highly talented and creative graduates capable of making a significant
contribution to global society. Much of the world aspires to a higher education
system as effective and as successful as ours at generating such creative graduates.

The introduction of a
teaching excellence framework (TEF)

Another major feature of the green paper is to create a
'teaching excellence framework', already affectionately known as the TEF, and
to link performance in this assessment process to permission to increase
undergraduate tuition fees in line with inflation. For understandable reasons,
there is deep concern about linking teaching excellence to a tuition fee rise
among students and their representatives, so this green paper will meet
significant resistance from the outset, despite the fact that it is intended to
'put students at the heart of higher education'. Some of our staff may share
those sentiments too.

In order to assess 'teaching excellence' we need, of course,
to know how to define and to measure it. Both aspects are problematic -
something that is clearly identified in the green paper. UCL's definition of
teaching excellence within the framework of a research-based pedagogy may not
coincide with the views of others - so who is right and who decides if UCL passes
the threshold or not?

We are going to have the opportunity to explain UCL's approach
in our multiple TEF submissions. There will be a submission for each academic discipline,
each of which will be reviewed and scored by an expert peer group panel. Much
of the detail of how this will work in practice needs to be defined as part of
the consultation. For the process to make sense at a disciplinary level, there
would need to be evaluation of something like the 45 disciplines that are
identified in the National Student Survey.

Since the proposal is for a rolling process of assessment, there
will clearly need to be 'standing' expert panels, readily available to assess new
submissions at any stage. This screams to me of significant cost and heavy-duty
bureaucracy. At whatever levels their fees are set, students will want to know
that university resources are directed towards an excellent student experience
rather than cumbersome administration, so we do need to be wary of this.

What measures will
TEF use?

The measures to be used by these peer review panels will be
proxy 'output' measures that will be subject to a more detailed technical consultation,
which is good, because the proposals start from a low base of knowing how best
to measure teaching quality. This is what the green paper currently suggests:

"We believe at present that there are three common metrics
(suitably benchmarked) that would best inform TEF judgements. We propose
initially to base the common metrics on existing data collections:

• employment/destination - from the Destination of Leavers
from Higher Education Surveys (outcomes), and, from early 2017, make use of the
results of the HMRC data match

• retention/continuation - from the UK Performance
Indicators which are published by Higher Education Statistics Agency (HESA)

The current intention is that in the first year of TEF, a level
1 award will be given to any institution with a current satisfactory QAA review
outcome - this
would include UCL, and the paper seems to indicate that this would allow UCL to
introduce an increase of 1% for the year 2017-2018 on this basis.
In subsequent years, we would be allowed to apply for higher levels of TEF
award (levels 2-4). This is what the green paper says on the relationship
between TEF level and the maximum tuition fee that may be set.

"We anticipate that government would set a maximum fee cap
to correspond to each TEF award level, i.e. a maximum fee an institution can
charge if it is assessed as level 1, level 2 etc. The government would not
pre-set a formula for this fee uplift, but would set the uplift each year,
maintaining the current model of basic and higher amounts, and not exceeding
real terms increases.

"Institutions would be able to charge fees up to the maximum
of their current TEF level fee cap. This would be regardless of their TEF
performance in previous cycles, so institutions will not be able to 'bank'
increases gained if they performed better on the TEF in previous years. We do
not envisage the fees charged to individual students changing during their
course."

Confused yet? Well let me take you through it, as I currently
understand the proposal.

Imagine it is 2018 and, after considerable discussion, we
decide to submit for a TEF level 4 award and prepare submissions for 45
disciplines that now go off to 45 peer review panels for assessment, and that
those panels also have access to national teaching excellence data as outlined
above.

That is a huge amount of (expensive) work for the
institution and for the assessment panels. The scores come back (presumably
normalised in some way for student numbers?) and they are in some (as yet
unidentified way) amalgamated to give an institutional result that indeed
confirms that we have achieved level 4 status.

That presumably now allows us to increase our fees for future
students by 100% of inflation. Let's presume that inflation (CPI?) in 2018
remains low at 1%. Our home/EU tuition fee income is approximately £100m per
annum and thus after filling all three years with students at the increased fee,
we will be
receiving an additional £3m per annum by 2021 .

Measured against our current annual turnover, that would be the
equivalent of up to 0.26%
income. So, it is fairly clear that this doesn't represent the way forward to
the sunny uplands of financial sustainability, and at this level we would be
unlikely to submit to TEF for purely financial reasons!

Of course, the hypotheticals that I have used (e.g.
inflation, or the maximum tuition fee uplift allowed by government) may change,
and that could alter the cost-benefit ratio to UCL. There would also be the likely
significant reputational benefit of a level 4 TEF award with respect to both
home/EU and international student recruitment.

Moreover, the green paper indicates that we could only enter
the TEF level 2-4 process if we were making satisfactory progress (signed off
by OFFA) with our widening participation targets and had also satisfied the
requirements of the Competition and Markets Authority with respect to the
information provided to students about our courses. This level of regulation and
intervention does indeed begin to feel like quite a significant threat to
institutional autonomy.

A new 'Office for
Students' - merging HEFCE, QAA and OFFA

My final topic to highlight from the green paper is the
proposal to 'simplify the higher education architecture'. The proposal is to
create a new 'Office for Students' that will absorb the functions of HEFCE, QAA
and OFFA, but crucially, under this model HEFCE is, in effect, disbanded, at
least in its current form. The green paper is not clear about the destination of
government teaching funding (for band A and B disciplines), but it does
speculate that such funding could be handled either directly from BIS or by the
Student Loans Company, and that it would not necessarily pass to the new Office
for Students.

A new responsibility for the new Office for Students would
be to "Ensure the system promotes the interests of students, employers and
taxpayers to ensure value for their investment in education".

If HEFCE ceases to function in its current form, this brings
into question how Quality of Research (QR) funding would be handled and
administered in the future. The green paper is cautious not to pre-empt the
forthcoming Nurse review, but the options seem to include QR being handled
either directly by BIS or in closer association with the Research Councils. The
green paper re-emphasises the critical benefits of the dual funding system and
attempts to protect dual funding into the future.

If these two funding streams are brought closer together, we
are, however, just a heartbeat away from them being folded together (and
possibly cut) at some point in the future. It is fundamentally important that
any future higher education bill has clauses that enshrine dual funding in
perpetuity, requiring a minimum of a further act of parliament to change that critically
important piece of higher education architecture.

There are many other elements of the green paper that I have
not covered in detail, such as social mobility and widening participation and
proposals to make it easier for new (private) providers to acquire University
status and Taught Degree Awarding Powers. These too are major changes that are
presented as being positive elements for student choice and for driving quality
and value for money.

The green paper in
summary: far-reaching changes to higher education

In summary, the green paper makes proposals that are far
reaching and that signal the most significant changes to higher education since
the introduction of tuition fees back in 1997. I have expressed my concerns
about the very basis of the need for such changes and I worry about the
unintended effects of such a concatenation of the rather far-reaching changes
that are currently proposed. We will need to see the outcomes of the Nurse review
and the comprehensive spending review before we can see the full landscape of
the future of higher education with any degree of certainty.

The practical aspects of running the TEF look daunting and
the link to setting tuition fees looks cumbersome to say the least. The good
news is that we have a chance, through the consultation process, to express our
views and concerns and we trust that BIS will listen. If you read UCL 2034, it
is very clear that we too want to put our students and their education at the
centre of higher education in our institution.

Our approach of closely linking research and education together
as a key factor in driving teaching excellence and providing an inspirational
student experience clearly differs from the more market-oriented and financially-driven
approach being suggested by government. We need to work hard to get BIS to see
that there are different ways forward that trust our universities to get this
right and that simultaneously support both the diversity of the sector and our institutional
autonomy.